In 2021, the Office of the Indiana State Chemist (OISC) state agencies began an audit of all registered Minimum Risk 25(b) Pesticide products to ensure they met the requirements outlined in AAPCO FIFRA 25(b) Workgroup guidance documents. To comply with this audit, all registrants were required to provide a market label, Confidential Statement of Formula (CSF), Efficacy data, Safety Data Sheet (SDS), and any available safety data for each minimum risk pesticide in the market.

In March of 2024, registrants began receiving audit results with label change and additional data requests from the Office of the Indiana State Chemist (OISC). SRC has been working with our clients to review audit results, meet response timelines, make label revisions, negotiate changes with OISC, and generate data to support efficacy claims.

Has Indiana requested revisions on your 25(b) registration documents?

If revisions are required or recommended – INTENT to make these revisions must be submitted to OISC by September 1, 2024.  If Indiana does not receive a response with your intent by this date it will be assumed you do not intend to revise the required documents.

All REVISIONS must be submitted by September 1, 2025.

SRC can assist with your audit response and help you meet the upcoming compliance deadlines.

Please read your audit results carefully, as the audit may require:

  • revisions to your website, label, SDS, or CSF
  • product reformulation
  • additional efficacy testing

If you are not planning to negotiate or make the revisions required by the audit, your product will begin discontinuance in 2025 and the product certificate will not be renewed for 2026. Further details along with FAQ can be found in the Audit Review Information Sheet

Our team will continue to monitor the progress of the Minimum Risk 25(b) Pesticide product audit and provide updates to clients throughout the process.

 

ADDITIONAL NOTE:

Five more inert ingredients (corn cobs, cottonseed meal, potassium bicarbonate, sodium benzoate and vinegar) will be added to the AAPCO 25(b) Inert Ingredient Guidance.  Currently, AAPCO is unable to provide any additional information on levels of concern.

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Thomas Spahr

Registration Specialist II

Posted on: 08/01/24